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5.19.26
Colorado Legislature Repeals and Replaces Colorado AI Act: What SB 189 Means for Your Business
On May 14, 2026, Colorado Governor Jared Polis signed SB 189 into law, which repeals and replaces the Colorado Artificial Intelligence Act (CAIA). SB 189 goes into effect on January 1, 2027.
Alerts
5.07.26
Recent AI Regulatory Developments in the United States
While the EU Artificial Intelligence (AI) Act has set forth a relatively uniform framework for AI regulation in the EU, U.S. AI regulation has so far primarily consisted of a patchwork of state laws—which continue to evolve at a rapid pace. Despite the Trump administration calling for Congress to pass AI legislation that would preempt overly burdensome state laws in its National Policy Framework for Artificial Intelligence, many states appear to be actively moving ahead with new legislation. Here are the top areas the states are targeting, followed by some key takeaways:
Alerts
11.13.25
Senator Cassidy Introduces Sweeping Health Privacy Bill
On November 4, 2025, Sen. Bill Cassidy (R-LA) introduced the Health Information Privacy Reform Act (the Act), which would, among other things, expand the privacy protections of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to health-related data handled by non-HIPAA-covered entities (“regulated entities” under the Act). The Act includes several provisions similar to Washington’s My Health My Data Act (MHMD),1 which extends privacy protections to “consumer health data” collected by entities that are not covered under HIPAA. The Act would also make some changes to existing HIPAA and Part 2 rules.
Alerts
7.03.25
Texas District Court Vacates 2024 HIPAA Rule Designed to Enhance Reproductive Healthcare Privacy, Effective Nationwide
On June 18, 2025, the United States District Court for the Northern District of Texas vacated most of the rules designed to enhance reproductive healthcare privacy promulgated by the U.S. Department of Health and Human Services (HHS) in 2024. More specifically, the court ruled in Purl v. United States Department of Health and Human Services et al, No. 2:2024cv00228 (N.D. Tex. 2025) (the Decision) that the “Health Insurance Portability and Accountability Act Privacy Rule to Support Reproductive Health Care Privacy” (the “2024 HIPAA Rule”) is contrary to law because it unlawfully limits state public health laws; impermissibly redefines certain terms in contravention of federal law and in excess of statutory authority; and exceeds HHS’s authority. Regulations promulgated under HIPAA prior to the 2024 HIPAA Rule remain unchanged.
Alerts
6.25.25
Nevada Passes Law Limiting AI Use for Mental and Behavioral Healthcare
On June 5, 2025, Nevada Governor Joe Lombardo signed AB 406, a law regulating the use of artificial intelligence (AI) for mental and behavioral healthcare. AB 406 comes as other states, such as Utah and New York, have taken steps to regulate AI chatbots, including AI chatbots providing mental health services. AB 406 prohibits offering AI systems designed to provide services that constitute the practice of professional mental or behavioral healthcare (such as therapy) and prohibits making representations that an AI system can provide such care. In addition, AB 406 limits how mental and behavioral healthcare professionals can use AI systems.[1] AB 406 takes effect on July 1, 2025.
Alerts
6.11.25
HHS Announces New Director of Office for Civil Rights: What to Watch from the New Health Privacy Leader
On June 4, 2025, the U.S. Department of Health and Human Services (HHS) announced the appointment of Paula M. Stannard as the Director of the Office for Civil Rights (OCR). As Director, Stannard will lead the enforcement of the Privacy, Security, and Breach Notification Rules under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as well as federal civil rights laws.
Alerts
4.15.25
Utah Enacts Mental Health Chatbot Law
On March 25, 2025, Utah Governor Spencer Cox signed HB 452, which establishes new rules for the use of artificial intelligence (AI) mental health chatbots accessible to any “Utah user,” defined as, “an individual located in the state at the time the individual accesses or uses a mental health chatbot.” Digital health companies and AI chatbot providers should take note of this new law to ensure compliance with its requirements.
Client Highlights
1.06.25
Wilson Sonsini Advises Clear Future on Purchase of FC2 Female Condom
On December 31, 2024, Veru Inc., a late clinical stage biopharmaceutical company focused on developing innovative medicines for preserving muscle for high quality weight loss, oncology, and viral induced acute respiratory distress syndrome, announced that it has sold its FC2 Female Condom® (Internal Condom) business to clients managed by Riva Ridge Capital Management LP, a New York City-based investment management firm, as well as other co-investors subject to adjustment as set forth in the purchase agreement. Wilson Sonsini Goodrich & Rosati advised Clear Future, Inc. on the transaction.
Alerts
8.23.24
FCC Issues Notice of Proposed Rulemaking Regarding the Use of AI-Generated Technologies for Consumer Communications
The Federal Communications Commission (FCC) recently issued a unanimous Notice of Proposed Rulemaking and Notice of Inquiry targeting the use of AI-related technologies for communicating with consumers.1 In the proposed rule, the FCC seeks to impose a broad definition for AI technologies subject to the requirements of the Telephone Consumer Protection Act (TCPA). Companies using technology falling within the FCC’s proposed definition would be required to make certain disclosures under the TCPA to notify consumers that they are communicating with AI-technology. This proposal is the latest move by the FCC to tackle its largest source of consumer complaints: unwanted and illegal robocalls and robotexts.2 The proposed new rule may require companies to modify their current approach in engaging with consumers through AI-generated calls and/or texts, including potentially altering their current practices in collecting consent where necessary.
Alerts
6.25.24
Texas District Court Vacates OCR's HIPAA Bulletin on Online Tracking Technologies, But Issues Mixed Decision
On June 20, 2024, the United States District Court for the Northern District of Texas ordered the U.S. Department of Health and Human Services, Office for Civil Rights (OCR) to vacate its guidance that had restricted HIPAA-covered entities’ use of third party online tracking technologies, such as common website advertising and analytics tools. In vacating the guidance, the court held that the agency exceeded its authority by redefining what is considered protected health information (PHI) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). While this order is a defeat for OCR’s guidance on online tracking technologies, regulated companies should react cautiously. The order could be appealed and potentially reversed, OCR could still bring enforcement actions in other circuits advancing their interpretation of PHI, and the Federal Trade Commission’s (FTC’s) laws and state privacy laws could still apply.
Client Highlights
6.20.24
Firm Advises Silk Road Medical on $1.26 Billion Acquisition by Boston Scientific
On June 18, 2024, Silk Road Medical announced that it entered into a definitive agreement to be acquired by Boston Scientific Corporation for a purchase price of $27.50 per share, reflecting an aggregate equity value of approximately $1.26 billion. Silk Road Medical is a medical device company that has developed an innovative platform of products to prevent stroke in patients with carotid artery disease through a minimally invasive procedure called transcarotid artery revascularization (TCAR). Wilson Sonsini Goodrich & Rosati advised Silk Road Medical on the transaction.